August 2017 JD Supra

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful.  The definition of “Willful” or “non-willful” in Taxpayer’s conduct makes a big difference in how civil or criminal penalties are assessed for unreported financial accounts. https://www.jdsupra.com/legalnews/are-you-a-taxpayer-identified-by-irs-55624/